Justia Montana Supreme Court Opinion Summaries

This interlocutory appeal arose from the district court's order certifying a class in Plaintiff's class action against Defendant, Allstate Insurance Company. Plaintiff's class action claim arose out of the Supreme Court's remand of his initial non-class third-party claim against Allstate in Jacobsen I. In Jacobsen I, Plaintiff filed a complaint against Allstate for, among other causes of action, violations of the Montana Unfair Trade Practices Act. Plaintiff sought both compensatory and punitive damages. The Supreme Court ultimately remanded the case for a new trial. On remand, Plaintiff filed a motion for class certification, proposing a class definition encompassing all unrepresented individuals who had either third- or first-party claims against Allstate and whose claims were adjusted by Allstate using its Claim Core Process Redesign program. The district court certified the class. The Supreme Court affirmed the class certification but modified the certified class on remand, holding that the district court did not abuse its discretion by certifying the Mont. R. Civ. P. 23(a)(2) class action but that the certification of class-wide punitive damages was inappropriate in the context of a Rule 23(b)(2) class. Remanded. View "Jacobsen v. Allstate Ins. Co." on Justia Law

Landowners protested pursuant to Mont. Code Ann. 76-2-205(6) to block the Board of County Commissioners of Missoula County from establishing a special zoning district north of Lolo, Montana. Landowners effectively blocked the zoning proposal pursuant to section 76-2-205(6). L. Reed Williams filed a complaint against Commissioners, challenging the constitutionality of the statute. Landowners intervened in the action. The district court denied Landowners' motion to dismiss and granted summary judgment to Williams and Commissioners, concluding that section 76-2-205(6) was an unconstitutional delegation of legislative power and an unconstitutional violation of the right to equal protection and the right to suffrage. The Supreme Court upheld the Commissioners' adoption of the special zoning district and affirmed the district court, holding that the district court did not err in (1) denying Landowners' motion to dismiss Williams' complaint for failure to join them as necessary parties; (2) determining that section 76-2-205(6) was an unconstitutional delegation of legislative power; and (3) ruling that section 76-2-205(6) was severable from the remainder of the statute. View "Williams v. Bd. of County Commr's" on Justia Law

Concerned that Defendant had collided with a fire hydrant, a police officer approached Defendant's vehicle and spoke to Defendant, at which time he noticed indicators that Defendant was driving under the influence of alcohol. The officer ultimately arrested Defendant and cited him for driving under the influence (DUI). Defendant filed a motion to suppress the evidence from the stop. The municipal court denied the motion, concluding that the caretaker doctrine started the stop, and it ripened into a proper DUI investigation. Defendant subsequently pled guilty to DUI. The district court affirmed the denial of Defendant's motion to suppress. The Supreme Court affirmed, holding that although the district court based its reasoning on the community caretaker doctrine, the motion to suppress was appropriately denied on the ground that there was particularized suspicion for the stop. View "State v. Marcial" on Justia Law

In 2010, Irene and John Moerman each signed an oil and gas lease with Prairie Rose Resources. In 2011, the Moermans filed a complaint for declaratory judgment claiming that their leases with Prairie had expired because, inter alia, Prairie had failed to establish oil production until after the expiration of the primary term of the lease. Prairie counterclaimed for a declaration that the lease remained in effect. The district court entered judgment in favor of Prairie and awarded Prairie its attorney fees and costs. The Supreme Court affirmed, holding (1) the district court correctly concluded that the parties' oil and gas leases remained in effect; and (2) because the Moermans failed to establish that the leases had been forfeited, Prairie's attorney fees in defending the action were recoverable. View "Moerman v. Prairie Rose Res., Inc." on Justia Law

Clifford Sabo and Sabo Brothers Construction (the Sabos) entered into a written lease agreement with Vernon and Laura Caldwell for the excavation of scoria, a substance used in road construction, on the Caldwells' land. The Sabos agreed to pay the Caldwells a royalty rate for all scoria sold from the Caldwells' land, but the lease was silent as to when royalty payments were to be made. For several months, the Sabos made royalty payments to the Caldwells but for another period of several months, the Sabos did not make any royalty payments at all. The Caldwells subsequently filed a complaint against the Sabos, alleging breach of the lease for failure to pay royalties in a timely manner. The Caldwells also filed an application for a preliminary injunction. The district court enjoined the Sabos from hauling or selling any scoria from the Caldwells' land, concluding that the Caldwells had made a prima facie case that the Sabos had not paid them for all the scoria sold. The Supreme Court reversed, holding that the district court erred in granting the Caldwells a preliminary injunction in a breach of contract action when pecuniary compensation was contemplated and would afford adequate relief. Remanded. View "Caldwell v. Sabo" on Justia Law

At issue in this case was a certain channel adjacent to the Yellowstone River. The disputed channel had been used for years to obtain river water to satisfy water rights held by Heart K Ranch. The City of Livingston owned land adjacent to the channel and argued that Heart K's maintenance activities in the channel harmed the City's property. The Park Conservation District (PCD) permitted Heart K's maintenance activities in the channel as provided in the Natural Steambed and Land Preservation Act. The City petitioned the PCD for a declaratory ruling that the channel was not subject to the permitting process in the Act because it was actually an irrigation ditch not subject to the Act. The PCD determined that the channel was part of the natural watercourse of the Yellowstone River, which was indisputably subject to the Act. The district court upheld the PCD. The Supreme Court affirmed, holding that the City failed to show that the PCD's decision was arbitrary or capricious, characterized by an abuse of discretion, or a clearly unwarranted exercise of discretion. View "Livingston v. Park Conservation Dist." on Justia Law

Timothy Watts sold real property to the Marions, who financed the purchase with one loan from PrimeLending and a second loan from Watts. Watts signed a subordination agreement agreeing to subordinate his loan to the PrimeLending loan. The Marions subsequently signed a deed of trust to PrimeLending and a trust indenture in favor of Watts. The Marions defaulted on the loan originating with PrimeLending, which assigned its interest in the loan to HSBC Bank. After a trustee's sale, HSBC purchased the property. The Marions also defaulted on the loan from Watts. Claiming to be unaware of the previous HSBC trustee's sale, Watts held his own trustee sale and was purchaser of record. After discovering HSBC claimed ownership of the property, Watts filed a complaint against HSBC and other parties claiming an interest in the property, seeking to quiet title to the property. The district court granted Watts' motion for summary judgment against HSBC, finding that the Marion debt to PrimeLending was no longer in the first priority lien position because the debt had been assigned to HSBC. The Supreme Court reversed, holding that HSBC's deed of trust in the property was clearly entitled to priority over Watts' subordinated trust indenture. View "Watts v. HSBC Bank USA, N.A." on Justia Law

As part of their dissolution of marriage, Viola and Gary entered into a mediated property settlement agreement. The district court approved the property settlement, deeming the property and debts "equitably distributed." The court then entered a decree of dissolution. Viola subsequently filed Mont. R. Civ. P. 59(e) and 60(b) motions seeking relief from the judgment, claiming that the property settlement agreement was unconscionable and failed to include a disclosure of assets as required by Mont. Code Ann. 40-4-254. The district court denied Viola's motions. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the motions in which Viola alleged that the property settlement agreement was unconscionable and that the district court failed to require a full disclosure of assets. View "In re Marriage of Anderson" on Justia Law

Carl and Karen were married in 1993. In 1995, Karen made Carl a co-owner of certain property. In 2007, the county clerk recorded a quit claim deed transferring Carl's interest in the property back to Karen. When the parties divorced in 2009, the district court concluded that Karen was the owner of the property and that the $100,000 increase in the property's value from 1993 to 2009 was due to market force and had nothing to do with any contributions made by Carl. In 2012, Carl filed a complaint alleging that Karen fraudulently forged Carl's signature on the deed to the property and that Alta, another defendant, notarized the forged signature. The district court dismissed the complaint on the grounds that the two-year statute of limitations for fraud claims had run. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly determined that Carl's fraud claim was barred by the statute of limitations; but (2) erred by awarding fees and costs to Defendants. View "Kananen v. South" on Justia Law

Decedent, the mother of Cathie and Marcy, died testate. Decedent's will expressly made no provision for her daughters. Decedent named Kristine Fankell as the personal representative of her estate. After Fankell's application for informal probate was accepted, Marcy filed a petition for supervised administration of the estate and a petition for formal probate of the will. Cathie subsequently filed an objection to the application and appointment of Fankell as personal representative as well as a motion for substitute of judge. The district court (1) denied Cathie's motion for substitution of judge as untimely, and (2) granted Fankell's motion to strike Cathie's pleadings because she failed timely to intervene and her interests were adequately represented by Marcy. The Supreme Court affirmed the district court's denial of Cathie's motion for substitution of judge, holding that the court correctly determined Cathie's motion was untimely. View "In re Estate of Quirin" on Justia Law